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Providing coverage of Alaska and northern Canada's oil and gas industry
June 2022

Vol. 27, No. 26 Week of June 26, 2022

AOGCC proposes reg changes; well control plan to be required

Kristen Nelson

Petroleum News

The Alaska Oil and Gas Conservation Commission is requesting public comment on proposed changes in its regulations, changes which include the addition of emergency well control contingency plans in advance of drilling permits.

In discussing the proposal for emergency well contingency plans, AOGCC said the new section “would transfer the requirement for operators to submit an emergency well control contingency plan to the AOGCC from the Alaska Department of Environmental Conservation.”

In addition to the proposed regulation, the commission has also included a draft guidance bulletin on the emergency well control contingency plans requirement.

Well control plan

Under the proposed regulations, the required emergency well control contingency plan is based on a company regaining control of the well within 15 days.

The commission said that prior to “any activities authorized by an application for a Permit to Drill (Form 10-401) or an application for Sundry Approvals (Form 10-403), the operator must submit and obtain the commission’s approval of an emergency well control contingency plan,” which may be approved for an area or field, “rather than for each well individually.”

The commission said required information includes location, site-specific procedures, methods, equipment, personnel, logistics, “and time frames proposed to be employed to regain control of the well within 15 days.” Certification of the resources necessary to commit the plan is required, “signed by a person with appropriate authority.”

The commission may require a formal drill with AOGCC present.

The plan will be a controlled document, with updates, “annually or at an interval acceptable to the commission,” to certify the plan covers current and proposed operations “and that information and best engineering practices are current.”

There must be a copy at each covered exploration or production facility.

For wells approved prior to the effective date of the regulation, the operator must submit a proposed plan within 60 days of the effective date of the regulation.

“Upon written request of the operator, the commission may, at its discretion, approve a variance from the requirements of this section if the variance provides at least an equally effective means of complying with the requirement.”

The plan covers “procedures, methods, equipment, personnel, logistics, and time frames that will be employed to regain control of an uncontrolled flow of oil, gas, drilling mud, and other substances from a well, including surface blowout.”

Guidance bulletin

A four-page industry guidance bulletin accompanying the proposed regulations explains in detail the emergency well control contingency plan requirements in the proposed regulations.

Details on the application process include: the plan must be submitted and approved prior to AOGCC approving applications for drilling permits or for sundry approvals; informal pre-applications meetings are encouraged; estimated plan approval time is 30 to 60 days after receipt of a complete plan; AOGCC will issue a unique plan ID once the plan has been approved.

Most of the guidance bulletin is devoted to describing required contents of the plan, including “facility diagrams detailing the pad and a well diagram”; description of procedures to regain well control within 15 days; “conditions that activate primary and secondary prevention measures”; “preliminary relief well planning” with a minimum of two locations identified for drilling a relief well and “an overview of appropriate drilling rigs that could potentially be mobilized, rig ownership, seasonal commitments and availability, and the rig staging or normal operating location(s).”

A description of the command system is required, with the notation that “the command system must be consistent with the operator’s state-approved Oil Discharge Prevention and Contingency Plan.”

A complete list of emergency well control equipment is required, including location and ownership and time frame for delivery and startup of emergency well control equipment, logistical support detail and deployment strategies.

If an emergency well control contractor is to be used, contact information for that contractor is required along with a statement of what that contractor is obligated to do.

Other regulatory changes

In addition to the new emergency well control contingency plan section, the commission proposes five other regulatory changes.

In the regulation on onshore location clearance, the proposed change adds language that site clearance for an individual well is not required when there is active production and/or injection at a location. The commission said the revision is based on public comments received in 2021.

In the regulation on offshore location clearance, the proposed change adds language state that site clearance is not required for an individual well when there is active production and/or injection at a location. The revision is based on public comments received in 2021.

In the regulation on workover operations, the revision specifies a completion date for work performed under a sundry and “is proposed to clarify that approved well work is to be completed expeditiously,” the commission said.

In the regulation on casing, cementing, and tubing of injection wells for enhanced recovery, disposal, and storage, the revision clarifies when tests must be performed, revises the required test pressure, establishes test acceptance criteria and specifies test equipment requirements, with a new subjection proposed to address standards for variances and waivers.

In the regulation on public and confidential information, language is added “stating that information submitted as part of an application for an order or hearing is not confidential unless entitled under some other provision of law.”

Hearing scheduled

Information on all proposed changes is available on the commission’s website: https://www.commerce.alaska.gov/web/aogcc.

Comments are due by 4:30 p.m. Aug. 4. The commission has scheduled a public hearing on the proposed regulations for Aug. 4 at 10 a.m. at its Anchorage offices, which may be changed to virtual if necessary. The audio call in information is 907-202-7104 conference ID 557 730 662#. Those wishing to participate by Microsoft Teams should contact Samantha Carlisle at the commission (907-793-1223) at least two business days prior to the conference.

- KRISTEN NELSON






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